the ceres accelerator for sustainable ......tony davis ceo and cio, inherent group jack ehnes chief...

ADDRESSING CLIMATE AS A SYSTEMIC RISK

A call to action for US financial regulators

EXECUTIVE SUMMARY

THE CERES ACCELERATOR FOR SUSTAINABLE CAPITAL MARKETS

ADDRESSING CLIMATE AS A SYSTEMIC RISK ceresorgaccelerator

For additional details references and endnotes please review the entire report at ceresorgaddressingclimate2

ACKNOWLEDGEMENTS

With deep thanks for support from ClimateWorks Foundation and other private funders

Report Author Senior Program Director Capital Markets Systems Ceres Veena Ramani

Managing Director Ceres Accelerator for Sustainable Capital Markets Steven M Rothstein

Chief Executive Officer and President Ceres Mindy Lubber Special thanks to Report Consultant Peyton FlemingThanks also go to the many colleagues at Ceres who provided invaluable assistance with this project including Blair Bateson Sam Burke Jim Coburn Maura Conron George Grattan Tim Green Cynthia McHale Ryan Martel Brian Sant Dan Saccardi Sara Sciammacco Troy Shaheen Alex Wilson and Elise Van Heuven

Project ContributorsCeres would like to thank the following people for contributing their valuable time and thoughtful feedback to this project and informing our recommendations The views expressed in this report are Ceresrsquo alone and do not necessarily reflect those of these contributors

Sarah Bloom Raskin former United States Deputy Secretary to the Treasury Former Member Federal Reserve Board of Governors Federal Reserve SystemLucinda Brickler former Senior Vice President New York Federal ReserveJay L Bruns Senior Climate Policy AdvisorWashington State Office of the Insurance CommissionerMark Carney Special Envoy for Climate Action and Finance United Nations former Governor the Bank of EnglandDave Cotney Senior Advisor FS VectorCarlos Curbelo former US Congressman Floridarsquos 26th Congressional District Principal Vocero LLC Thomas Curry Partner Nutter McClennen amp Fish LLP Tony Davis CEO and CIO Inherent Group Jack Ehnes Chief Executive Officer CalSTRS Rick Fleming Investor Advocate US Securities and Exchange CommissionGregg Gelzinis Senior Policy Analyst Center for American Progress Julie Gorte Senior Vice President Sustainable Investing Impax Asset ManagementIlmi Granoff Director of Sustainable Finance Program ClimateWorks FoundationAndy Green Managing Director Economic Policy Center for American ProgressRobert Hirth Senior Managing Director Protiviti Co-vice chair Sustainability Accounting Standards Board (SASB) Chairman emeritus Committee of Sponsoring Organizations of the Treadway Commission (COSO) Bob Inglis former US Congressman South Carolinarsquos 4th Congressional District Executive Director republicEnorg Dave Jones Senior Director for Environmental Risk The Nature ConservancyJonas Kron Senior Vice President Trillium Asset ManagementAlexandra Ledbetter Senior Corporation Finance Counsel to the Investor Advocate US Securities and Exchange Commission Bob Litterman Partner Kepos Capital Leonardo Martinez-Diaz Global Director Sustainable Finance Center World Resource Institute Timothy Massad Former Chair US Commodity Futures Trading Commission Former Assistant Secretary for Financial Stability US Department of the Treasury Mike Peterson Deputy Commissioner on Climate and Sustainability California Department of Insurance Eric Pitt Consultant Ken Pucker Board Chair Timbuk2Janet Ranganathan Vice President of Research Data and Innovation World Resource InstituteSue Reid Principal Advisor Finance Mission2020 Samantha Ross Founder AssuranceMark the Investors Consortium for AssuranceMary Schapiro Vice Chair for Global Public Policy and Special Advisor to the Founder and Chairman Bloomberg LP Barney Schauble Chair Nephila Climate Graham Scott Steele Director Corporations and Society Initiative Stanford Graduate School of Business Damon Silvers Director Policy and Special Counsel AFL-CIO Anne Simpson Interim Managing Investment Director CalPERS Staff National Association of Insurance Commissioners (NAIC) Marilyn Waite Program Officer Environment Hewlett Foundation Cynthia Williams Professor Osgoode Hall Law School York University Betty Yee Controller State of California



LETTER FROM THE CHAIR

I am thrilled that this new Ceres report ldquoAddressing Climate as a Systemic Risk A call to action for US financial regulatorsrdquo identifies so many important recommendations to address the systemic risk that the climate crisis presents I have spent many years in risk markets at the intersection of capital markets and insurance so I am particularly aware of the importance of climate risk in both industries We hope that this first report from the new Ceres Accelerator for Sustainable Capital Markets will contribute to the critical discussions among federal and state regulators legislators and others focused on these issues I hope you will consider joining us to advocate for these changes as quickly as possible

Barney SchaubleChair Ceres Board of DirectorsChairman Nephila Climate

About the Ceres Accelerator for Sustainable Capital Markets

The Ceres Accelerator for Sustainable Capital Markets (the ldquoCeres Acceleratorrdquo) aims to transform the practices and policies that govern capital markets in order to accelerate action on reducing the worst financial impacts of the global climate crisis and other sustainability threats The Ceres Accelerator will spur capital market influencers to act on these systemic financial risks and drive the large-scale behavior and systems change needed to achieve a net-zero carbon economy and a just and sustainable future For more information visit ceresorgaccelerator

This work is licensed under CC BY-NC-ND 40 To view a copy of this license visit httpscreativecommonsorglicensesby-nc-nd40



REPORT FOREWORD (EXCERPT) Read the entire foreword in the full report at ceresorgreports

The ongoing COVID-19 pandemic reminds us daily of what we miss in our beautiful world and how interconnected and interdependent we all are The pandemic has exposed that the US is particularly vulnerable to shocks that hit our collective well-being like those related to health and climate that financial markets cannot perform the work of assuring collective well-being and that the magnitude of a crisis is determined not just by the impact of precipitating events but by the fragility of the system it attacks The world has been forced into a recalibration of values hellip

ldquoAddressing Climate as a Systemic Riskrdquo underscores that it is possible to act before catastrophe and that there is opportunity in preemptive early and bold actions by federal economic policy makers looking to avoid catastrophe The tools exist They are available now and ready to be picked up and deployedhellip

With both breadth and depth Ceres offers more than 50 specific recommendations covering seven key federal financial regulatory agencies along with state and federal insurance regulators These recommenda-tions outline the affirmative steps regulators should take to protect the financial system and economy from potential climate-related shocks that can flatten an economy and grind it to dust Climate change affects financial stability and [in this report] Ceres provides the action plans for federal financial regulators to do the work to protect that stability -- nowhellip

At the very least we must rebuild with an economy where the values of sustainability are explicitly embedded in market valuation Letrsquos leave behind our former sense of whatrsquos possible while moving toward an environment and an economy that we have confidence--this time--can be sustained

Sarah Bloom RaskinFormer United States Deputy Secretary of the TreasuryFormer Member Federal Reserve Board of Governors

A CALL TO ACTION FOR US FINANCIAL REGULATORS ceresorgaccelerator


EXECUTIVE SUMMARY

Systemic risks have the potential to destabilize capital markets and lead to serious negative consequences for financial institutions and the broader economy Under this definition climate change like the current COVID-19 crisis is indisputably a systemic risk Its wide-ranging physical impacts combined with expected transitions to a net-zero carbon economy and other socio-economic ripples are likely to manifest in both cumulative and unexpected ways and present clear systemic risks to US financial markets -- and the broader economy Left unmanaged these risks could have significant disruptive consequences on asset valuations global financial markets and global economic stability

This Ceres report ldquoAddressing Climate as a Systemic Risk A call to action for US financial regulatorsrdquo outlines how and why US financial regulators who are responsible for protecting the stability and competitiveness of the US economy need to recognize and act on climate change as a systemic risk It provides more than 50 recommendations for key financial regulators to adopt including the Federal Reserve Bank (the Fed) the Office of the Comptroller of the Currency (OCC) the Federal Deposit Insurance Corporation (FDIC) the Securities and Exchange Commission (SEC) the Commodity Futures Trading Commission (CTFC) state and federal insurance regulators the Federal Housing Finance Agency (FHFA) and the Financial Stability Oversight Council (FSOC)

Given the ongoing response to the COVID-19 pandemic the role of financial regulators is more prominent than ever While financial regulators are taking critical actions to support the US economy in response to this immediate crisis it is imperative that their efforts do not inadvertently worsen the impacts of climate change

ldquoThe evidence on climate risk is compelling investors to reassess core assumptions about modern finance Research from a wide range of organizations ndash including the UNrsquos Intergovernmental Panel on Climate Change the BlackRock Investment Institute and many others including new studies from McKinsey on the socioeconomic implications of physical climate risk ndash is deepening our understanding of how climate risk will impact both our physical world and the global system that finances economic growthrdquo

ldquoThese questions are driving a profound reassessment of risk and asset values And because capital markets pull future risk forward we will see changes in capital allocation more quickly than we see changes to the climate itself In the near future ndash and sooner than most anticipate ndash there will be a significant reallocation of capitalrdquo Larry Fink Chairman and CEO BlackRock ldquoA fundamental reshaping of financerdquo Finkrsquos 2020 CEO Letter to BlackRock portfolio companies




Frequent extreme weather events are leading to mounting economic losses Physical risks from rising global temperatures ndash up 18deg F since the mid-20th century ndash are the most immediate threat to the US economy Catastrophic flooding droughts wildfires and storms are becoming more frequent and extreme and have caused billions of dollars in financial losses As global greenhouse gas (GHG) emissions and temperatures continue to rise deeper economic losses are projected for the years ahead

The Fourth National Climate Assessment (Vol11) based on the work of thousands of researchers suggests that unmitigated climate change could reduce the US economy by as much as 10 annually by 2100 In a 2019 CDP survey 215 of the worldrsquos largest listed companies reported nearly $1 trillion at risk from climate impacts much of it in the next five years A London School of Economics study projects that unless it is addressed climate change could reduce the value of global financial assets by as much as $24 trillion ndash resulting in permanent damage that would far eclipse the scale of the 2007-2009 financial crisis

Social and environmental factors are exacerbating the economic impacts Unmitigated climate change and extreme weather events will have significant health impacts including respi-ratory issues the spread of diseases and premature deaths Climate change and extreme weather events will also create major productivity losses particularly in industries that require workers to be outside Migration forced by climate change has already displaced an average of 264 million people per year globally between 2008 and 2015 By 2050 climate change will force 50 to 700 million people to emigrate Finally the rapid loss of forests and other ecosystems is starting to impact ecosystem-dependent industries such as agriculture tourism drinking water and pharmaceuticals

Climate impacts are already manifesting in the largest state economies In just the last few years California has experienced recording-breaking wildfires in both number and size that have taken hundreds of lives bankrupted the statersquos largest utility left millions regularly without power and brought home insurability into question Florida is facing rapidly rising sea levels and now-routine flooding that are eroding coastal property values and wiping out freshwater supplies Texas experienced two devastating once-in-a-thousand-years flood events between 2016 and 2019 each caused by torrential rains of 40 inches or more

An unplanned transition to a low-or-zero-carbon economy could cripple key industries Changes in government policies consumer sentiment liability risks and technological innovation could cause significant losses for high-carbon industry sectors and those that rely on them Given the large size of these industries these cumulative losses could send broad intersecting and amplifying financial ripples on major financial institutions holding related assets

Economists and financial leaders say the scale of the losses from climate change could eclipse the subprime mortgage securities meltdown that triggered bank failures and ultimately a deep global recession a dozen years ago ldquoEven if only a fraction of the [climate] science is right this is a much more structural long-term crisis [than the 2007-2009 recession]rdquo said BlackRock CEO Larry Fink in 2020

Despite these risks national and global efforts to mitigate climate changersquos impacts could create enormous clean energy investment opportunities that would translate into economic growth and job creation Research suggests that transitioning to a low-carbon sustainable economy could deliver direct economic gains of $26 trillion through 2030 compared to business as usual



Insurance companies and banks are on the frontlines of risk The insurance sector is particularly vulnerable to the physical impacts of climate change and has already faced growing losses insurersrsquo investments are also at risk Banks and financial institutions that have lent to and invested in risky carbon-intensive sectors have the potential to have their investments become ldquostrandedrdquo in the face of the transition to a low-or-zero-carbon future

The cumulative and unpredictable nature of climate impacts poses a risk to financial market stability While any of the impacts outlined above are significant their cumulative correlated and nonlinear nature poses the real risk to financial market stability To put it simply the whole is not only greater than the sum of its parts ndash it magnifies them as well If climate change affects markets suddenly and unexpectedly it could burst a ldquocarbon bubblerdquo which could pose grave dangers to financial markets and the real economy already weakened from the ongoing coronavirus pandemic

At the same time the response to the pandemic has also underscored the power financial regulators have to buttress markets in the face of a disruptive risk With that power regulators also have the responsibility to assess market vulnerability to such risks and take action to make the economy resilient to such shocks As stewards of the largest economy in the world US financial regulators including the Federal Reserve the SEC and others have critical roles to play They can send the appropriate market signals about the risks posed by climate change to the US and global economy and take the necessary steps to recalibrate our financial system

ACTIONS NEEDED

This report outlines why and how key US financial regulators can and should take action to protect the financial system and economy from potentially devastating climate-related shocks Financial regulators have a mandate to maintain financial market stability foster capital growth and competi-tiveness protect consumers and investors and ensure market efficiency and integrity Climate risk is relevant to each of these considerations

This report focuses on the roles of those financial regulators that Ceres believes are particularly important to jumpstart the necessary action on climate risk now However we also believe that all regulators ndash financial and otherwise ndash have important roles to play in addressing the climate risk ldquoAddressing Climate as a Systemic Riskrdquo makes a series of recommendations that build on the existing mandates of the relevant regulatory agencies We also identify similar actions being taken by global regulators that could serve as important models for US agencies to consider



Our key recommendations

The Federal Reserve System including the Federal Reserve Bank shouldbull Acknowledge that climate change poses risks to financial market stability and immediately begin

assessing their impacts This includes building awareness of regional climate vulnerabilities and conducting the needed research

bull Integrate climate change into their prudential supervision and regulation of systemically important financial institutions to ensure they adequately address climate change as a part of their risk manage-ment and are well prepared for transition risks One clear opportunity is to require financial institutions to conduct climate stress tests Another opportunity is to work with the SEC and other agencies to require banks to assess and disclose climate risks including carbon emissions from their lending and investment activities Finally the Fed should coordinate with its global counterparts to define activities that are likely to exacerbate climate risks

bull Explore how climate risks can be addressed through monetary policy to keep the economy resilient in the face of disruptive risks This policy assessment should include considering the climate impacts of injecting more liquidity into the economy and integrating climate risk into collateral frameworks and economic outlook assessments

bull Explore the integration of climate risk into the community reinvestment process to bolster the resilience of low-income communities to climate change

bull Join efforts such as the Network for the Greening the Financial System and to allow for globally coordinated efforts on climate risks

The Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation shouldbull Coordinate with each other and all banking regulators to ensure that climate change is integrated into

the financial supervision process This integration could include jointly issuing a bulletin highlighting the wide ranging ways that climate risks could impact financial performance and outlining principles to help financial institutions prudently manage them

bull (OCC) update the Comptrollerrsquos Handbook to issue enhanced guidance on climate risk to examiners to be used in supervision of financial institutions They should also integrate climate-risk supervision into the examiner education process

bull (FDIC) closely monitor the impacts of climate risk on bank lending and investments activities and explore how to integrate climate risk into the risk-based premium system for the Deposit Insurance Fund

ldquoWhen you put all these pieces together it becomes pretty clear climate change is an economic issue we canrsquot afford to ignore

This isnrsquot just a concern for the Twelfth District Or even the United States Countries around the world are dealing with the economic impacts of climate change And conferences like this are essential to understanding the challenges that lie ahead ndash for all of us

Ultimately this is our job The San Francisco Fed is a public service organization Wersquore responsible for the people and the communities we serve So we have to get out in front of this issue and do what we do best

Convene the best people and ideas Study data and conduct research Talk to the communities we serve ndash and really listen when they tell us what they needrdquoMary DalyPresident and CEO Federal Reserve Bank of San FranciscoldquoWhy climate change matters to usrdquo November 2019



The Securities and Exchange Commission shouldbull Analyze climate risk impacts on the securities markets and on the SEC mandate and consider

establishing a cross-divisional taskforce to allow for coordinated responses

bull Make clear that consideration of material environmental social and governance (ESG) risk factors such as climate change is consistent with investor fiduciary duty

bull Issue rules mandating corporate climate risk disclosure building on the framework established by the Financial Stability Boardrsquos Task Force on Climate-related Financial Disclosures (TCFD) In the short term the SEC should enforce the existing regulations and interpretive guidance on climate risk

bull Direct the Public Company Accounting Oversight Board (PCAOB) overseen by the SEC to assess whether firm audits adequately detect climate risks and issue guidance to help auditors better understand how climate risk affects audits and accounting The PCAOB should also assess existing standards to identify when amendments and updates may be needed and issue such amendments

bull Encourage the Financial Accounting Standards Board to drive consistency in the way that climate risk is disclosed in financial statements

bull Issue guidance encouraging credit raters to provide more disclosure on how climate risk factors are factored in ratings decisions They could also examine the extent to which climate risk is considered by credit raters and summarize findings in annual examination reports

The Commodity Futures Trading Commission shouldbull Upon receiving the Climate-Related Market Risk

Subcommitteersquos report engage other financial regulators on climate change

bull Use the reportrsquos recommendations to enhance oversight of climate risk in the commodities and derivatives market

State and federal insurance regulators shouldbull Acknowledge the material risks climate change poses to the in-

surance sector and pledge coordinated action to address them

bull Assess the adequacy of current insurer actions for addressing climate risks

bull Join the Sustainable Insurance Forum

bull Require insurance companies to conduct climate risk stress tests and scenario analyses to evaluate potential financial exposure to climate change risks

bull Require insurers to integrate climate change into their Enterprise Risk Management (ERM) and Own Risk and Solvency Assessments (ORSA) processes

bull (State regulators) require insurance companies to assess and manage their climate risk exposure through their investments and examine how climate trends affect company holdings and long-term solvency

bull (State regulators) encourage insurers to develop products for the new technologies practices and business models that will emerge in response to climate risk that are responsive to both risks and opportunities

bull (State regulators) mandate insurer climate risk disclosure using the TCFD recommendations

bull Assess the sectorrsquos vulnerabilities to climate change and report findings to the Financial Stability Oversight Council

ldquoWe purport to modernize without mentioning what may be the single most momentous risk to face markets since the financial crisis Where we should be showing leadership we are conspicuously silent In so doing we risk falling behind international efforts and putting US companies at a competitive disadvantage globallyrdquoAllison Herren LeeCommissioner Securities and Exchange CommissionldquolsquoModernizingrsquo Regulation S-K Ignoring the elephant in the roomrdquo January 2020



The Federal Housing Finance Authority responsible for government-sponsored mortgage giants Freddie Mae and Fannie Mae should

bull Acknowledge the impacts of climate risk on the housing market

bull Conduct research to examine the impacts of climate risk on the mortgage holdings of Government-Sponsored Enterprises particularly Fannie Mae and Freddie Mac

bull Launch a formal effort to develop strategies to address climate risk being particularly aware of the impacts on vulnerable communities disproportionately threatened by climate change

The Financial Stability Oversight Council whose mandate is to identify risks to financial stability should

bull Identify climate risk as a vulnerability and make recommenda-tions on regulations that relevant agencies could adopt

bull Coordinate regulatory actions on climate change and the integration of efforts by all financial regulators addressing climate risk to allow for overall financial stability

CONCLUSION

Ceres knows that climate change is the biggest sustainability issue of our time affecting everything from our financial markets to our political security to our very existence on earth For over three decades Ceres has worked with companies investors and policy makers to drive the consideration of climate change as a financial risk and foster the uptake of climate solutions We also believe that legislative action on climate change ndash such as a carbon price ndash is necessary to move the US economy towards a competitive and prosperous net-zero carbon future

But while policymakers at the federal state and global levels need to take the lead in tackling the climate crisis US financial regulators themselves have critical roles to play in keeping a now-weakened economy resilient in the face of ongoing and future climate shocks Rather than standing back they should seize the opportunity in this moment of potential economic transformation to join global peers and develop a playbook for climate action With global emissions and average temperatures still rising watching and waiting are no longer responsible options and will in fact guarantee the worst And unlike in the possible resolution to the COVID-19 pandemic there will never be vaccines developed to protect against climate risk But the good news is we already have all the tools and knowledge in the financial markets to take sound preventative action

Climate change presents risks to both the future and today -- unless regulators act boldly now

ldquoIn the crowded regulatory and supervisory space there is limited scope for focusing attention on new issues but climate risks need immediate action in order to limit or reverse the impact of some of the negative trends under way It is incumbent on supervisors to put in place the necessary measures for insurers to address any significant risks that could adversely affect policyholders and financial stability In previous financial crises events once deemed implausible have materialized Climate change poses the same threatrdquoBank of International SettlementsldquoTurning up the heat Climate risk assessments in the insurance sectorrdquo 2019



ACKNOWLEDGEMENTS

With deep thanks for support from ClimateWorks Foundation and other private funders

Report Author Senior Program Director Capital Markets Systems Ceres Veena Ramani

Managing Director Ceres Accelerator for Sustainable Capital Markets Steven M Rothstein

Chief Executive Officer and President Ceres Mindy Lubber Special thanks to Report Consultant Peyton FlemingThanks also go to the many colleagues at Ceres who provided invaluable assistance with this project including Blair Bateson Sam Burke Jim Coburn Maura Conron George Grattan Tim Green Cynthia McHale Ryan Martel Brian Sant Dan Saccardi Sara Sciammacco Troy Shaheen Alex Wilson and Elise Van Heuven

Project ContributorsCeres would like to thank the following people for contributing their valuable time and thoughtful feedback to this project and informing our recommendations The views expressed in this report are Ceresrsquo alone and do not necessarily reflect those of these contributors

Sarah Bloom Raskin former United States Deputy Secretary to the Treasury Former Member Federal Reserve Board of Governors Federal Reserve SystemLucinda Brickler former Senior Vice President New York Federal ReserveJay L Bruns Senior Climate Policy AdvisorWashington State Office of the Insurance CommissionerMark Carney Special Envoy for Climate Action and Finance United Nations former Governor the Bank of EnglandDave Cotney Senior Advisor FS VectorCarlos Curbelo former US Congressman Floridarsquos 26th Congressional District Principal Vocero LLC Thomas Curry Partner Nutter McClennen amp Fish LLP Tony Davis CEO and CIO Inherent Group Jack Ehnes Chief Executive Officer CalSTRS Rick Fleming Investor Advocate US Securities and Exchange CommissionGregg Gelzinis Senior Policy Analyst Center for American Progress Julie Gorte Senior Vice President Sustainable Investing Impax Asset ManagementIlmi Granoff Director of Sustainable Finance Program ClimateWorks FoundationAndy Green Managing Director Economic Policy Center for American ProgressRobert Hirth Senior Managing Director Protiviti Co-vice chair Sustainability Accounting Standards Board (SASB) Chairman emeritus Committee of Sponsoring Organizations of the Treadway Commission (COSO) Bob Inglis former US Congressman South Carolinarsquos 4th Congressional District Executive Director republicEnorg Dave Jones Senior Director for Environmental Risk The Nature ConservancyJonas Kron Senior Vice President Trillium Asset ManagementAlexandra Ledbetter Senior Corporation Finance Counsel to the Investor Advocate US Securities and Exchange Commission Bob Litterman Partner Kepos Capital Leonardo Martinez-Diaz Global Director Sustainable Finance Center World Resource Institute Timothy Massad Former Chair US Commodity Futures Trading Commission Former Assistant Secretary for Financial Stability US Department of the Treasury Mike Peterson Deputy Commissioner on Climate and Sustainability California Department of Insurance Eric Pitt Consultant Ken Pucker Board Chair Timbuk2Janet Ranganathan Vice President of Research Data and Innovation World Resource InstituteSue Reid Principal Advisor Finance Mission2020 Samantha Ross Founder AssuranceMark the Investors Consortium for AssuranceMary Schapiro Vice Chair for Global Public Policy and Special Advisor to the Founder and Chairman Bloomberg LP Barney Schauble Chair Nephila Climate Graham Scott Steele Director Corporations and Society Initiative Stanford Graduate School of Business Damon Silvers Director Policy and Special Counsel AFL-CIO Anne Simpson Interim Managing Investment Director CalPERS Staff National Association of Insurance Commissioners (NAIC) Marilyn Waite Program Officer Environment Hewlett Foundation Cynthia Williams Professor Osgoode Hall Law School York University Betty Yee Controller State of California



















EXECUTIVE SUMMARY





















ACTIONS NEEDED




















































CONCLUSION























EXECUTIVE SUMMARY





















ACTIONS NEEDED




















































CONCLUSION




















ACTIONS NEEDED




















































CONCLUSION






















































CONCLUSION





the ceres accelerator for sustainable ......tony davis ceo and cio, inherent group jack ehnes chief...

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